Is mitigation possible?

18th October 2018

Mitigation measures can be proposed but many impacts are not capable of being adequately mitigated.

Have Highways England done their homework on what the cost of mitigating their 5A Arundel bypass would be, so far as it can be done (which is not far enough)? We think not. And we think that if they did this job properly, they would cancel the scheme as being beyond budget.

Part I Mitigation/compensation opportunities at the western end of Arundel Bypass Route 5A
by Dr Emma Tristram

Much of the damage the bypass route would cause cannot be mitigated, for instance, the ruin of the tranquillity and special character of part of the National Park landscape (Binsted Woods and their associated fields, and part of Binsted village). The damage to protected and unique habitats which the bypass would cause also cannot be mitigated. These include Ancient Woodland, a chalk stream, and veteran trees which, even if they initially survive construction of the bypass, would be severely impacted by being next to a busy road through pollution and compaction of roots. The severance and loss of character of the ancient Binsted Parish, a remarkable unity between huge woods, fields and village, also cannot be mitigated.

The ‘workshop’ which was proposed by Highways England for 10 October 2018 was stated to be about mitigation of the ‘western tie-in junction’. But restriction of the workshop to mitigating this one aspect of the bypass is typical of Highways England’s continuing misunderstanding about the nature, size, position and importance of Binsted Woods, and the impact of the bypass on them and on the National Park. Mitigating the proposed junction’s impact would make very little difference to the highly damaging impact of the whole western section of the bypass.

The environmental and landscape impact of the eastern section is also severe. This paper focuses only on the western section because that is the author’s area of special knowledge, and that is the area which impacts the National Park most.

Damage from the bypass route misrepresented in 2017 and 2018

Judging by the information presented in the 2017 consultation, Highways England are unaware of the true location and character of Binsted Woods (100 ha of semi-natural broad-leaved woodland), and hence the damage the bypass would do. For instance, a false statement was made that no option had a ‘significant impact’ on semi-natural broad-leaved woodland (Highways England, Environmental Survey Report, 2017, Table 8.5).[1] Reports for the Department of Transport as part of previous bypass studies show that on the contrary, the new bypass would substantially damage a woodland area of ‘national importance’. The Scheme Assessment Report of 2018 also contained misunderstandings about Binsted Woods, for instance, four new viewpoints labelled ‘Binsted Woods’ were actually of parts of Tortington Common.

To correct this apparent lack of knowledge, it is important to point out that the ‘Binsted Woodland Complex’ (then defined as Binsted Woods and some of their connecting fields, and a strip of woodland along the south side of Tortington Common) was stated in 1992 to be of ‘national importance’ by the Department of Transport’s consultants (the Environmental Assessment Unit of Liverpool University Limited or EAULUL) as part of previous bypass studies. They stated that ‘destruction or fragmentation would substantially damage its national importance’.

Fig. 1: The ‘nationally important’ woodland complex as defined by Department of Transport consultants in 1992, with the route of the new Preferred Route superimposed

The area said to be ‘nationally important’ has not changed since then and its ecological richness is now far better known through the studies organised by MAVES, Mid Arun Valley Environmental Survey. The species list of 1992 was enough to lead EAULUL to state that the area was of national importance, but would now be far longer. As an example, EAULUL’s surveyors found 5 species of bat in Binsted Woods, but there are now known to be 14.

The area said to be ‘nationally important’ includes some fields, and also includes all the parts of Binsted Woods (some 5 woodland compartments out of 20) that are not designated Ancient Woodland. The fields are part of the mosaic of habitats regarded as ‘nationally important’. EAULUL specifically stated in its report that the non-designated parts of Binsted Woods have similar species to the designated parts, and that being adjacent to Ancient Woodland has allowed them to regenerate. The woodland surrounding Binsted Park, to the south, is therefore just as important ecologically as the woodland at Little Danes Wood, Hundred House Copse and Barns Copse (all Ancient Woodland) that would be damaged by or close to the ‘western tie-in junction’.

Since the new bypass route does partially destroy and fragment the nationally important woodland complex then defined, substantial mitigation and/or compensation measures would be needed, proportionate to the damage that would be done, as well as proportionate to the damage to the South Downs National Park, Binsted village and Binsted Park.

Damage to the National Park

Highways England cannot be properly compliant with their statutory duty to ‘have regard to’ the National Park, unless they conduct their assessments in the light of the fact that the planning protection and status of National Parks is as high as or higher than that of Ancient Woodland. The Special Qualities of the National Park may be expressed equally in undesignated high-quality woodland or other habitats and views as in designated Ancient Woodland. ‘Regard to the Park purposes’ requires the impact on those Special Qualities to be mitigated or compensated for. As a reminder, the Special Qualities are:

Diverse, inspirational landscapes and breathtaking views

A rich variety of wildlife habitats including rare and internationally important species

Tranquil and unspoilt places

An environment shaped by centuries of farming and embracing new enterprise

Great opportunities for recreational activities and learning experiences

Well-conserved historical features and a rich cultural heritage

Distinctive towns and villages and communities with real pride in their area

The suggestions for mitigation/compensation below all relate to one or more of these Special Qualities. Damage to Special Quality 1, the landscape itself and the inspirational views of woods and fields, could not be repaired so this Special Quality is not mentioned. Damage to the other Special Qualities would be impossible to mitigate or compensate for in a way commensurate to the damage done, but since some possible measures exist, they should be put in place if the bypass goes ahead.

Essential compensation or mitigation measures if the bypass goes ahead

The below are initial suggestions only. With regard to further mitigation and enhancement opportunities, identification and prioritisation, the following should be consulted:

Green bridges and tunnels are methods for mitigating harm to wildlife and to recreational access – see Special Qualities 2 and 5. Four green bridges or, where practicable, tunnels would be needed, to continue or improve access into the National Park, to provide crossings for wildlife, and to lessen the impact of the new road on walkers, riders and cyclists. I suggest (see Fig. 2):

One green bridge across the existing A27 at Hundred House Copse (restoring the route of the present north-south bridleway cut off by the A27);

One green bridge across the existing A27 east of Paine’s Wood (restoring the mostly disused footpath that at present runs north-south along the eastern edge of Paine’s Wood);

One green bridge or tunnel across the new road itself at Scotland Lane; and

One green bridge or tunnel on the route of Footpath 342 from Binsted Church through the woods to Arundel.

To the south, across Binsted Park and its surrounding woodland, where the bypass would be on an embankment, across several important routes for bats and other wildlife, a green bridge would not be possible and tunnels might not be effective. A better solution might be to put the bypass in a low and enclosed bridge.

Since the western tie-in junction has been redesigned in the Scheme Assessment Report to have access roads passing under the new road, whereas in 2017 they were going to pass over it, and the junction may be still further redesigned, it is not clear whether the new road would be elevated, at grade, or in a cutting in the vicinity of Binsted Lane West, Scotland Lane and Footpath 342, hence whether a bridge or a tunnel would be needed.

The aims of the green bridges/tunnels should include ‘ecological, landscape and access functions’, as described in ‘Green Bridges: Technical Guidance Note 09/2015’, by the Landscape Institute, published by Natural England. All the possible aims they list are needed in this case.

Note that green bridges ‘may provide a localised benefit for landscape, but will not mitigate the impacts of linear transport infrastructure over a wide area’. This is especially true since the area where they are needed is in the South Downs National Park. They are therefore to be regarded as partial compensation rather than mitigation.

Fig. 2: Locations for Green Bridges or tunnels

The Landscape Institute article lists 12 ‘key drivers’ for ‘considering if a green bridge is an appropriate option’. This scheme fulfils almost all of these. Under ‘ecological drivers’ the article lists:

‘Severance of a designated site’: the scheme would sever the Binsted Woods Complex Local Wildlife Site. More broadly, the National Park itself is a designated site and would be severed.

‘Severance of species commuting routes, e.g. bats’: the scheme would sever the commuting routes to the south and west of several of the 14 bat species known in Binsted Woods.

‘Severance of rare habitats or habitats of local importance’: the scheme will sever a woodland area acknowledged in 1992 to be of ‘national importance’, including Ancient Woodland.

‘Identification of local biodiversity benefits’: reconnecting what remained of the LWS south of the present A27 with the rest of the National Park.

Under ‘Landscape’ the article lists as drivers:

‘Severance…within an historic landscape’: the scheme would sever and partially destroy the historic landscape of Binsted, containing Iron Age earthworks and enclosures, an Anglo-Saxon Moot Mound, two mediaeval tile kilns and a remnant of mediaeval Arundel Forest.

‘Infrastructure to be sited within a statutory designated landscape’: the scheme is within the South Downs National Park.

‘Severance of a highly valued or sensitive feature of importance to local character (e.g. small lanes)’: the scheme crosses Binsted Lane twice – a small lane which is a highly valued feature of the landscape. It would not be severed but its value to the landscape would be lost.

‘Local benefits a green bridge could provide, e.g. creating an iconic structure’: this would be in keeping with the scheme’s destruction of part of the National Park.

Under ‘Access’ the article lists as drivers:

‘Severance of an access route, e.g. … a bridleway’: Green Bridges 1-2 would restore the historic severance by the A27 of two important north/south access routes, one a bridleway. Green Bridges 3-4 would restore the severance of the historic track Scotland Lane and FP 342 – both much used east/west access routes.

‘Severance between residential areas and … rural areas’: Green Bridges 1-2 would reconnect the residential areas of villages to the south and west to the South Downs National Park north of the present A27; Green Bridges 3-4 would maintain their access to the National Park south of the present A27 and the Arun valley which would otherwise be interrupted by the scheme.

The recommended width for a Green Bridge built for ecological reasons is 80m. If other uses are added on, such as footpath, cycle and horse access, the width should be increased, or – ideally – a separate bridge would be constructed for those purposes.

Binsted church

The future of Binsted Church, the centrepiece of historic Binsted Parish (Special Quality 6), would be in doubt if the bypass was constructed. Ten houses in the village of 38 houses are within the National Park. About half the historic Parish is within the National Park and though the church is just outside the boundary, the village’s pride in its heritage (Special Quality 7) has led to fundraising to help its upkeep for 31 years. Over that period over £100,000 has been raised.

Since the peaceful setting of this beautiful 12th-century church would be destroyed by the bypass, its present congregation might well cease to attend and its future as a church with regular services would be in doubt. To assure the church a long-term future as a historic building, various restoration works are needed which even the yearly ‘Strawberry Fair’ fundraising event by Friends of Binsted Church has been unable to pay for. They are:

Replacing the cementitious mortar which at some stage in the 20th century was used all over the south wall of the church, causing damp problems, with an appropriate lime mortar. I have seen quotes of up to £50,000 for the whole job.

Restoring the remaining 12th-century wall painting so that it looks as it did in 1888 (fortunately its appearance then was recorded and a print of this image hangs next to it in the church). The present restoration is unfortunate and looks nothing like the image as it looked in 1888 shortly after its rediscovery.

Examination of the inside of the south wall by an expert to see if anything remains of the other wall paintings then discovered, which covered the whole church. Replacement of the failed plaster if not.

New and effective anti-damp measures, if they are needed after the replacement of the mortar.

Redecoration of the inside of the church which is suffering very badly from damp.

Replacement of the wooden shingles on the spire, last replaced in the late 1990s.

Restoration of the mediaeval-style ‘Cosmati pavement’ in the chancel, the work of architect Thomas Graham Jackson in the restoration of 1868. Few of these are known (there is a wall at St Mary’s, Slindon using the same technique, also by Jackson) and the components are glass. Some tesserae are missing or scratched.

Binsted village and Church Farm

The bypass would go through Binsted village from one end to the other, 75m from the closest three houses and just over 200m from 11 more, some of them listed. Four houses would be split from the other 34. The village would be ruined and its community, which organises village events such as the Strawberry Fair and the Binsted Arts Festival, would disperse. Special Qualities 6 and 7 would be damaged. Binsted village is more than its houses – the houses are unified with the fields and woods by their layout and they form a ‘tranquil and unspoilt place’ (Special Quality 3) which would be ruined.

Church Farm, Binsted is fulfilling National Park Special Quality 4 with new enterprises within Binsted Woods such as the Ratpack Archers archery club and the Forest Knights countryside courses. Since its fields would be almost impossible to work after the road was built, I suggest Highways England should acquire all seven fields through which it would pass and plant new woodland, with rides and glades, in the arable areas. Pasture could be allowed to grow up into new natural woodland. Some areas, such as the two small fields within Binsted Woods (Broad Green and Scotland Field), are noted areas for orchids with thousands each year, and special treatment for those might be needed such as keeping them open and regular mowing. The best treatment for what remained of Binsted Park might be to let it grow up into woodland, or to fence areas to form wood-pasture with grazing animals. See below under ‘E’ for another suggestion – part of a ‘new wildwood’.

The new woodland would eventually provide at least a psychological and visual barrier between the nearest houses and the road. The new road should also have the best low-noise surface and screening bunds and/or sound-mitigating barriers either side of it along its entire length. Lights should be kept to a minimum.

Binsted Woods

National Park Special Qualities 2 and 3 would be badly affected by the damage to Binsted Woods from the bypass. Binsted Woods are 100 ha of semi-natural woodland, all within the historic Binsted parish and entirely within the South Downs National Park. As seen above, they form almost the whole of the area declared in 1992 to be of ‘national importance’ and their national importance would be ‘substantially damaged’ by the bypass. About 20 ha of very good woodland would be severed and become much less good for wildlife. Up to 14 ha would be destroyed. About 15 ha of the remaining woods would be degraded by being alongside a major road.

Binsted Woods are made up of various different combinations of broadleaved woodland but are mainly ash and oak, and are mainly overgrown coppice-with-standards in which the coppice stools have grown tall. They contain many storm-damaged trees which have been left to lie and have then regrown, with new verticals from the horizontal trunk. This is one of the features of Binsted Woods and they should not be tidied up too much. They also contain much lying dead wood which provides a host of niches for a wide range of our rarer beetles reliant on a dead wood habitat. It is one of our rarest habitats.

If 14 hectares of Ancient Woodland were destroyed by the bypass, using the multiple of 7 for compensation planting would give an area of 98 ha of new woodland that would be required. The suggested new woodland in the 7 fields surrounding the bypass could make up some of this. Some re-coppicing in Binsted Woods could be undertaken at the same time which would improve their already very high wildlife value and produce more woodland flowers and be better for butterflies. This would be some compensation for the very severe damage described above.

The woodlands known as The Lag and The Shaw (part of the woodland surrounding Binsted Park) are wooded stream valleys connecting the Ancient Woodland of Lake Copse to the main block of Ancient Woodland in Binsted Woods. These are vital corridors for dormice, reptiles, and amphibians, and for the area’s 14 species of bat. The Shaw has an exceptionally large veteran badger sett complex and The Lag also has a sett. Crossing these stream valleys with embankments as proposed cannot be acceptable. Less damaging solutions must be found, e.g. possibly a low and enclosed bridge for the new road.

Tortington Common

Both Binsted Woods and Tortington Common, the regenerating conifer plantation woodland to the east of Binsted Woods, are in the National Park and should be regarded as one woodland area (though made up of two very different kinds of woodland) which deserves the best possible treatment. Conifer plantations are ecologically very poor in comparison to broad-leaved woodland, but the woodland can gradually recover and restoration work can help. Tortington Common has much improved over the last 30 years (since the 1987 storm). Where it was a combination of conifers with chestnut coppice (planted to provide a succession of game cover), the chestnut has grown tall and the impression is of semi-natural woodland. Parts of it, such as Steward’s Copse and the southernmost strip, were never coniferised. But it could be improved still further by a programme of restoration.

Tortington Common has a large amount of invasive alien Rhododendron ponticum, laurel and bracken, which are poor habitats for wildlife, and work to reduce these is costly and difficult. Parts of Tortington Common have been sold to new small woodland owners (I think 13 small woods overall), and some are doing a great job of improving habitats, such as re-coppicing old coppice stools, and building natural fences to keep deer away from the regrowth. Other new owners are cutting their woods for firewood indiscriminately and could benefit from guidance.

A programme of work in Tortington Common, liaising with the owners to continue the regeneration to broadleaved woodland of the conifer areas, and removing some of the bracken and all of the laurel and rhododendron, would be very beneficial and would also help to compensate for the severe damage to neighbouring Binsted Woods.

Together, Binsted Woods and Tortington Common, along with the proposed new woodland in the seven fields surrounding the bypass at Binsted, could form a ‘new wildwood’ as described in a report by National England in 2002 (‘New Wildwoods in Britain’, LUPG report). They described this as:

The area of Binsted Woods, Tortington Common and the suggested new woodland planting would make a possible ‘new wildwood’ which already has all of these aspects.

Archaeology

National Park Special Quality 6 would be severely damaged by the bypass because it would destroy an important section of the Iron Age monument – a linear ditch and bank - known as War Dyke.

Part of War Dyke, the section leading east from the top of the Downs to the River Arun, is a scheduled monument. The section leading south from the top of the Downs, all the way through historic Binsted Parish from north to South, to join up with the Tortington Rife brook which forms the east-west southern parish boundary and flows into the Arun, is not scheduled but is regarded by archaeologists as part of War Dyke. It has largely been ploughed out in the fields at Binsted but an impressive double section remains in Hundred House Copse which has been protected by being in woodland.

The purpose of the monument seems to have been to delineate or defend an area defined partly by the ditch and bank, and partly by the watercourses of the Tortington Rife and the River Arun. Such ditches and banks linking watercourses or the sea are known in other parts of the country – Chichester and Colchester. They are known as ‘territorial oppida’.

The area enclosed by War Dyke and the watercourses includes two Iron Age rectangular enclosure monuments at Gobblestubbs Copse, just north of the A27 in the historic Binsted Parish. These have been excavated by Worthing Archaeological Society and written up by archaeologist David McOmish. But the purpose of both the enclosures and the dykes is still little known. The writer Graham Robb suggests that the areas defined are areas in which Celtic tribes traded with the Romans, and compares them to ‘new towns’.

The section of War Dyke within Hundred House Copse, which would be destroyed by the bypass, is double – i.e. it consists of two earth banks side by side. The only other double section is at the top of the Downs. The purpose of these double sections is not known.

If the bypass is built, I suggest that in compensation for destroying this double section of War Dyke, Highways England not only allows a ‘rescue dig’ of the bank and ditch to take place before the road works begin, but also endows an archaeology professorship at Chichester or Southampton University whose purpose would be further research into the systems of dykes both at Binsted and at Chichester.

Binsted Park

The ‘historic parkscape’ known as Binsted Park, within Binsted Woods, would be destroyed by the bypass. This fact was disguised in the 2017 consultation by a long list of errors and misstatements (see footnote 1).

Binsted Park is part of Binsted’s rich cultural heritage (National Park Special Quality 6) and its distinctive community with real pride in its area (Special Quality 7). A descendant of the Read or Staker-Read[2] family who created the landscaped Park in about 1800 still lives in the Park. He holds a large, but uncatalogued, collection of historic photos not only of the Park but also of other places in Binsted. He is related not only to the Read family but also to the Lewis family who lived at the Old Rectory in the later 1800s, one of them being the Reverend Henry Lewis, who organised and paid for the restoration of Binsted Church in 1868 with the services of architect Thomas Graham Jackson, and to the Pethers family, who kept the Black Horse pub, Binsted, in the 1960s. One of Henry Lewis’s sons was an early photographer and some photographs date back to the 1860s.

This precious archive should be catalogued and digitised as part of the compensation for destroying Binsted Park, an important and much-loved area within both Binsted Woods and Binsted Village. The digital files, with notes identifying the people in the photos (the present owner of the photos can name almost everybody) should be deposited in the Record Office.

Conclusion

No details of mitigation or its costs were revealed in the 2017 consultation. Immediately after the consultation had ended, Highways England revealed that it had calculated the ‘compensation planting’ for the destruction of Ancient Woodland for the three options it presented on a basis of a multiple of 7 for the area of Ancient Woodland destroyed. No mention was made of compensation for damage to anything else, for instance, to nationally important woodland that is not designated, or to the Special Qualities of the National Park. This suggests that Highways England have radically underestimated the damaging nature of the bypass.

The above list contains no costings, but if even a small proportion of the suggested work was done the perceived economic benefit of the road scheme would plummet still further from its present barely-acceptable Benefit Cost Ratio figure of 1.51 (reduced in 2018 from the figure of 2.6 given in the 2017 consultation), and the project would become uneconomic.

[1] My analysis of the use of ‘Fake News’ and misinformation by Highways England can be found at:

From Climping to Littlehampton there is a cycle and pedestrian friendly lane, where I would recommend a speed limit, ideally 20 mph. There is a byway leading south to the sea. There needs to be more cycle parking at Climping beach.

Climping Street should have a 20mph speed limit.

Ford station has no (legal) footpath access to the river Arun, so anyone looking to get out at Ford and walk along the river has to walk along the main road. Extend the existing path east to the river to allow access to the river.

Extend the existing footpath north of Ford station going west, which goes past the mini industrial estate and cottages, to join up westwards to the two footpaths coming south from Binsted and north from Ford lane. This would also offer the option of a detour so that walkers could cross the road at Ford station rather than riskily crossing the railway line.

A footpath from Ford prison to the river, east from Ford Road.

Ford lane should have a 20 mph speed limit and the lane redesigned to encourage walkers, pedestrians and horse riders.

A shared cycle/pedestrian way from A 27 at Walberton to Yapton and linking to Ford Lane.

A shared cycle/pedestrian way along the B2233

20mph limit and redesign of lane between Yapton Road and Ford Road.

All of the above should help link housing estates, light industry areas, beaches, Ford prison and so on by a network of cycle and pedestrian ways that would reduce the need for cars. The area is flat so ideal for all levels of cyclists.

There needs to be a pedestrian/cycle bridge over the A27 to enable easy access to the SDNP north of the A27 from Binsted woods.

Ford station should be considered a gateway station to the South Downs National Park. The area south of the A27 is particularly suitable for wheelchair, buggy and bicycle access from the train, along a new cycle/pedestrian way and into Tortington and Binsted woods. More prominence should be given to accessing the SDNP from Ford station.

The new Saltern Way is advertised as suitable for cyclists and wheelchairs: https://www.visitchichester.org/activity/salterns-way The footpath from Slate Barn Farm to Tortington could be upgraded to a hard surface byway, making it suitable for wheelchairs, pedestrians and cyclists in all weathers.

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